Privacy Policy

This Privacy Policy outlines our policies and procedures regarding the collection, use, and disclosure of your information when you use the Service. It also informs you of your privacy rights and how the law protects you. We use your personal data to provide and enhance the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation
Words with capitalized initial letters have meanings specified under the following conditions. These definitions shall apply consistently, regardless of whether the terms are used in singular or plural form.

Definitions
For the purposes of this Privacy Policy:

• Affiliate refers to any entity that controls, is controlled by, or is under common control with a party, where "control" signifies ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for the election of directors or other managing authority.

• Application refers to Remote TV, the software program provided by the Company.

• CCPA/CPRA refers to the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act of 2020 (CPRA).

• Company (referred to as "the Company," "We," "Us," or "Our" in this Agreement) refers to Xleum Software Limited. For the purposes of GDPR, the Company is the Data Controller.

• Consumer (for the purposes of CCPA/CPRA) means a natural person who is a California resident. A resident, as defined by law, includes (1) any individual in the USA for a non-temporary or non-transitory purpose, and (2) any individual domiciled in the USA but temporarily outside the country.

• Data Controller (for the purposes of GDPR) refers to the Company as the legal entity that alone or jointly with others determines the purposes and means of processing personal data.

• Device means any electronic device that can access the Service, such as a cellphone or tablet.

• GDPR refers to the EU General Data Protection Regulation.

• Service refers to the Application.

• Service Provider means any natural or legal person who processes data on behalf of the Company. This includes third-party companies or individuals employed by the Company to facilitate the Service, provide the Service on behalf of the Company, perform services related to the Service, or assist the Company in analyzing how the Service is used. For the purposes of GDPR, Service Providers are considered Data Processors.

• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (e.g., the duration of a page visit).

• You refers to the individual accessing or using the Service, or the company or other legal entity on whose behalf the individual is accessing or using the Service. Under GDPR, You may also be referred to as the Data Subject or the User, as you are the individual using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data
While using our Service, we may ask you to provide certain personally identifiable information that can be used to contact or identify you. This information may include, but is not limited to:

• Email address

• Usage Data

Usage Data
Usage Data is automatically collected when you use the Service. This data may include details such as your Device's Internet Protocol (IP) address, browser type and version, the pages of our Service that you visit, the time and date of your visit, the duration spent on those pages, unique device identifiers, and other diagnostic data. When accessing the Service through a mobile device, we may collect information such as the type of mobile device you use, your mobile device’s unique ID, its IP address, the operating system, the type of mobile Internet browser, unique device identifiers, and other diagnostic data. We may also collect information sent by your browser whenever you visit our Service or access it through a mobile device.

Information Collected while Using the Application
When using our Application, we may collect certain information from your device to provide features of the Application, with your prior permission. This may include:

• Photos and other data from your device’s camera and photo library

We use this information to provide and improve features of our Service. The data may be uploaded to the Company’s servers or a Service Provider’s server, or it may simply remain stored on your device. You can enable or disable access to this information at any time through your device settings.

Use of Your Personal Data
The Company may use your personal data for the following purposes:

• To provide and maintain our Service, including monitoring its usage.

• To fulfill contracts: This includes the development, compliance, and execution of any contracts with us through the Service.

• To contact you: We may contact you via email or other electronic communication methods, such as push notifications from the mobile application, regarding updates or information related to the functionalities, products, or services you’ve contracted, including necessary security updates.

• To manage your requests: We process your requests to us.

• For business transfers: Your information may be used to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which personal data held by us about our Service users is among the assets transferred.

• For other purposes: Your information may be used for other purposes, such as data analysis, identifying usage trends, and improving our Service, products, services, and overall user experience.

We may share your personal information in the following situations:

• For business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.

Retention of Your Personal Data
The Company will retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy. We will retain and use your personal data as needed to comply with legal obligations, resolve disputes, and enforce our legal agreements and policies. Usage Data will be retained for internal analysis purposes. Generally, Usage Data is retained for a shorter duration, unless it is required to strengthen the security or improve the functionality of our Service, or if we are legally obligated to retain it for a longer period.

Transfer of Your Personal Data
Your information, including personal data, is processed at the Company's operating offices and in any other locations where the involved parties are situated. This means your information may be transferred to—and maintained on—computers outside your state, province, country, or other governmental jurisdiction, where data protection laws may differ from those in your jurisdiction.

By consenting to this Privacy Policy and submitting your information, you agree to this transfer. The Company will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy, and no transfer of your personal data will occur to an organization or country unless adequate controls are in place to protect your data and other personal information.

Delete Your Personal Data
You have the right to delete or request assistance in deleting the personal data we have collected about you. Our Service may allow you to delete certain information directly within the Service. You can update, amend, or delete your information at any time by visiting the settings section where you manage your personal information. Alternatively, you may contact us to request access to, correct, or delete any personal information you have provided. Please note that we may need to retain certain information when we have a legal obligation or valid reason to do so.

Disclosure of Your Personal Data

Business Transactions
If the Company is involved in a merger, acquisition, or asset sale, your personal data may be transferred. We will provide notice before your personal data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement
In certain situations, the Company may be required to disclose your personal data if mandated by law or in response to valid requests by public authorities (e.g., a court or government agency).

Other Legal Requirements
The Company may disclose your personal data in good faith when necessary to:

• Comply with a legal obligation

• Protect and defend the rights or property of the Company

• Prevent or investigate potential wrongdoing in connection with the Service

• Protect the personal safety of users of the Service or the public

• Protect against legal liability

Security of Your Personal Data
The security of your personal data is important to us, but remember that no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use acceptable means to protect your personal data, we cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data
The Service Providers we use may have access to your personal data. These third-party vendors collect, store, use, process, and transfer information about your activity on our Service in accordance with their Privacy Policies.

Analytics
We may use third-party service providers to monitor and analyze the use of our Service.

• Google Analytics
  Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service, and this data may be shared with other Google services.
  You can opt out of certain Google Analytics features through your mobile device settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy.
  For more information on Google’s privacy practices, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy.

• Firebase
  Firebase is an analytics service provided by Google Inc.
  You can opt out of certain Firebase features through your mobile device settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy.
  We also encourage you to review Google’s policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.
  For more information on what type of information Firebase collects, please visit the "How Google uses data when you use our partners' sites or apps" webpage: https://policies.google.com/technologies/partner-sites.

Legal Basis for Processing Personal Data under GDPR
We may process your personal data under the following conditions:

• Consent: You have given your consent for processing your personal data for one or more specific purposes.

• Performance of a contract: Processing is necessary for the performance of a contract with you and/or for any pre-contractual obligations.

• Legal obligations: Processing is required to comply with a legal obligation to which the Company is subject.

• Vital interests: Processing is necessary to protect your vital interests or those of another natural person.

• Public interests: Processing is related to a task carried out in the public interest or in the exercise of official authority vested in the Company.

• Legitimate interests: Processing is necessary for the legitimate interests pursued by the Company.

The Company will gladly clarify the specific legal basis applicable to the processing of your personal data, particularly whether the provision of data is a statutory or contractual requirement, or necessary to enter into a contract.

Your Rights under the GDPR
The Company is committed to respecting the confidentiality of your personal data and ensuring you can exercise your rights. Under this Privacy Policy and, if you are within the EU, by law, you have the right to:

• Access Your Personal Data: You have the right to access, update, or delete the information we hold about you. You can do this directly within your account settings or by contacting us if you are unable to perform these actions yourself. This also allows you to receive a copy of your personal data.

• Correct Your Personal Data: You have the right to have any incomplete or inaccurate information corrected.

• Object to Processing: You can object to the processing of your personal data where we are relying on a legitimate interest as the legal basis and there is something about your particular situation that makes you want to object.

• Request Erasure: You can request that we delete or remove your personal data when there is no valid reason for us to continue processing it.

• Request Data Transfer: We will provide your personal data in a structured, commonly used, and machine-readable format either to you or to a third party you choose. This right only applies to automated information for which you initially provided consent or where we used the information to perform a contract with you.

• Withdraw Consent: You have the right to withdraw your consent to using your personal data at any time. If you withdraw your consent, we may not be able to provide certain functionalities of the Service to you.

Exercising Your GDPR Data Protection Rights
You may exercise your rights of access, rectification, cancellation, and opposition by contacting us. We may need to verify your identity before responding to your requests. We will respond as promptly as possible. You also have the right to lodge a complaint with a Data Protection Authority about our collection and use of your personal data. If you are in the European Economic Area (EEA), contact your local data protection authority for more information.

CCPA/CPRA Privacy Notice (California Privacy Rights)
This privacy notice for California residents supplements the information in our Privacy Policy and applies solely to visitors, users, and others residing in California.

Categories of Personal Information Collected
We collect information that can identify, relate to, describe, reference, or be associated with a particular consumer or device. The following list includes categories of personal information we may collect or have collected from California residents within the last twelve (12) months. The categories and examples are defined under the CCPA/CPRA and do not imply that all examples were collected. Instead, they reflect our good faith belief that some information from each applicable category may have been collected:

• Category A: Identifiers.
  Examples: Real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, driver’s license number, passport number, or similar identifiers.
  Collected: Yes.

• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
  Examples: Name, signature, Social Security number, physical characteristics, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment history, bank account number, credit card number, or health insurance information. Some overlap with other categories.
  Collected: Yes.

• Category C: Protected classification characteristics under California or federal law.
  Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion, marital status, medical condition, disability, sex (including gender identity, pregnancy, etc.), sexual orientation, veteran status, genetic information.
  Collected: No.

• Category D: Biometric information.
  Examples: Genetic, physiological, behavioral characteristics, fingerprints, faceprints, voiceprints, iris or retina scans, keystroke patterns, and health data.
  Collected: No.

• Category E: Internet or similar network activity.
  Examples: Interaction with our Service.
  Collected: Yes.

• Category F: Geolocation data.
  Examples: Approximate physical location.
  Collected: No.

• Category G: Sensory data.
  Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
  Collected: No.

• Category H: Professional or employment-related information.
  Examples: Current or past job history or performance evaluations.
  Collected: No.

• Category I: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
  Examples: Education records such as grades, transcripts, class lists, student schedules, financial information.
  Collected: No.

• Category J: Inferences drawn from other personal information.
  Examples: Profile reflecting preferences, characteristics, psychological trends, behavior, attitudes, intelligence, abilities.
  Collected: No.

• Category K: Sensitive personal information.
  Examples: Account login and password, geolocation data.
  Collected: Yes.

Sources of Personal Information
We obtain the above categories of personal information from:

• Directly from You: For example, from forms you complete or preferences expressed on our Service.

• Indirectly from You: For example, from observing your activity on our Service.

• Automatically from You: For example, through cookies we or our Service Providers set on your device as you navigate our Service.

Use of Personal Information
We may use or disclose the personal information we collect for business purposes as defined under the CCPA/CPRA, including:

• Operating and providing our Service.

• Supporting and responding to your inquiries, addressing concerns, and improving our Service.

• Complying with law enforcement requests and legal requirements.

• For internal administrative and auditing purposes.

• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activities, and prosecuting responsible parties.

The examples provided are illustrative and not exhaustive. For more details on how we use your information, refer to the "Use of Your Personal Data" section. If we decide to collect additional categories of personal information or use it for materially different purposes, we will update this Privacy Policy.

Your Rights under the CCPA/CPRA
If you are a California resident, the CCPA/CPRA provides you with specific rights regarding your personal information, including:

• Right to Notice: You have the right to be informed about the categories of personal data being collected and its intended use.

• Right to Know/Access: You can request that we disclose what personal information we have collected, including categories of data, sources, business purposes, third parties with whom we share it, and specific data collected.

• Right to Correct: You can request correction of any inaccurate personal information we hold about you.

• Right to Limit Use of Sensitive Information: You can request limitations on the use or disclosure of certain sensitive personal information.

• Right to Delete: You can request the deletion of your personal data, subject to certain exceptions.

• Right Not to Be Discriminated Against: You have the right not to be discriminated against for exercising any of your rights under the CCPA/CPRA.

Exercising Your CCPA/CPRA Data Protection Rights
To exercise your rights under the CCPA/CPRA, if you are a California resident, you can contact us:

• By email: feedback@xleumsoftware.com

• By visiting this page on our website: www.xleumsoftware.com

Only you or a person registered with the California Secretary of State authorized to act on your behalf may make a verifiable request related to your personal information. Your request must:

• Provide sufficient information to verify your identity or authorization to make the request.

• Describe your request in enough detail to allow us to understand, evaluate, and respond.

We cannot respond to your request if we cannot verify your identity or authority to make the request. We will provide the required information free of charge within 45 days of receiving your verifiable request, with an extension of an additional 45 days if necessary. Disclosures will cover the 12-month period preceding the request.

For data portability requests, we will provide your personal information in a readily usable format to enable transmission from one entity to another.

Limit the Use or Disclosure of My Sensitive Personal Information
If you are a California resident, you have the right to limit the use and disclosure of your sensitive personal information to what is necessary to perform the services or provide the goods reasonably expected by an average consumer. We collect, use, and disclose sensitive personal information as necessary to provide the Service. For more information, refer to the "Use of Your Personal Data" section or contact us.

Links to Other Websites
Our Service may include links to external websites that are not operated by us. If you click on a third-party link, you will be redirected to that third party's site. We strongly recommend that you review the Privacy Policy of every site you visit. We have no control over and are not responsible for the content, privacy policies, or practices of any third-party sites or services.

Changes to this Privacy Policy
We may update our Privacy Policy periodically. Any changes will be communicated by posting the revised Privacy Policy on this page. We will notify you of significant changes via email and/or a prominent notice on our Service before the changes take effect, and we will update the "Last updated" date at the top of this Privacy Policy. We encourage you to review this Privacy Policy regularly for any updates. Changes to this Privacy Policy become effective as soon as they are posted on this page.

Contact Us
If you have any questions about this Privacy Policy, you can contact us:

• By email: feedback@xleumsoftware.com

• By visiting this page on our website: www.xleumsoftware.com